Last Updated: February 9, 2026

This Privacy Policy explains how Otus Labs, Inc. (“Otus,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards personal information when you access or use our websites, mobile applications, software, APIs, and related services (collectively, the “Services”), or otherwise interact with us.

Pre-Launch Notice

Otus and the Services are currently in a pre-launch state. During pre-launch, the Services may be limited to informational pages, waitlists, onboarding, identity verification, communications, and similar functionality. Users may not yet be able to deposit funds or access certain product features. This Privacy Policy applies to personal information we collect during pre-launch and after launch.

1. Scope and Related Notices

This Privacy Policy applies to personal information we process through the Services and our business operations.

U.S. financial privacy (GLBA). If and when we provide a financial product or service to U.S. consumers that is subject to the Gramm–Leach–Bliley Act (GLBA), we may provide an additional GLBA Consumer Privacy Notice describing our information-sharing practices and any applicable opt-out rights for certain sharing of “nonpublic personal information.” If there is a conflict between this Privacy Policy and a GLBA notice we provide for covered information, the GLBA notice controls.

2. Personal Information We Collect

We collect personal information from (a) you, (b) your devices, (c) your activity on the Services, and (d) third parties (such as identity verification, compliance, banking/payment, and analytics providers).

A. Information you provide

Depending on how you use the Services (including during pre-launch), you may provide:

• Identifiers and contact information: name, email address, phone number, mailing address, date of birth, username, and similar identifiers.
• Waitlist / onboarding information: interest areas, referral codes, responses to onboarding questionnaires, and preferences you choose to share.
• Identity verification and compliance information (KYC/AML): government-issued ID information (including ID numbers and images), selfies/liveness checks, proof-of-address documents (if requested), and verification or screening results (e.g., sanctions screening), as well as other information you provide to complete compliance checks.
• Financial account information: linked-account identifiers and funding/withdrawal instructions.
• Communications: messages and content you send us (support tickets, emails, chat messages), survey responses, and feedback.

B. Information we collect automatically

When you use the Services, we may automatically collect:

• Device and network information: device type, operating system, browser type, device identifiers, IP address, and mobile network information.